Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined deficiencies in petitioner's Federal income tax for its fiscal years ending October 31, 1974, and October 31, 1975, in the amounts of $4,026.05 and $9,204.26, respectively. The sole issue presented for decision is whether petitioner's accumulation of earnings for the years in issue was beyond the reasonable needs of its business and for the purpose of avoiding income tax...
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